Cheerleader Can't Be Kicked Off Pa. High School Team Over Snapchat Post Saying 'Fuck Cheer,' 3rd Circuit Rules
Eyeing school discipline over social media posts, and when they run afoul of constitutional free-speech protections, a three-judge panel of the U.S. Court of Appeals for the Third Circuit granted summary judgment Tuesday in favor of the student who challenged the school's decision.
June 30, 2020 at 03:12 PM
4 minute read
The original version of this story was published on The Legal Intelligencer
A divided federal appeals court panel has ruled that a central Pennsylvania school violated a student's rights when it kicked her off the cheerleading team after she posted a Snapchat message saying, among other things, "fuck cheer."
Eyeing school discipline over social media posts, and when they run afoul of constitutional free-speech protections, a three-judge panel of the U.S. Court of Appeals for the Third Circuit granted summary judgment Tuesday in favor of the student who challenged the school's decision.
The majority opinion in the case, captioned B.L. v. Mahanoy Area School District, ruled that the school's decision to remove her from the team violated her First Amendment rights.
The appeals court affirmed a ruling from the U.S. District Court for the Middle District of Pennsylvania.
The Third Circuit panel addressed open questions about how to differentiate between "on-campus" and "off-campus" speech in the digital age, and whether the U.S. Supreme Court's seminal 1969 decision in Tinker v. Des Moines Independent Community School District can be applied to a student's "off-campus" speech.
Judge Cheryl Ann Krause, writing for the majority, said it was clear the student's comment was made off-campus, and further determined that Tinker, which said students could only be censored for speech that disrupted the educational process, did not apply to off-campus speech.
"It is the off-campus statement itself that is not subject to Tinker's narrow recognition of school authority. But at least in the physical world, that is nothing new," Krause said. "We simply hold today that the 'online' nature of that off-campus speech makes no constitutional difference. "
In making the ruling, Krause said she hoped it would provide guidance to courts and school administrators struggling to determine what student speech can be restricted in the digital age.
Judge Stephanos Bibas joined Krause, but Judge Thomas Ambro filed a concurring opinion, saying the court prematurely reached the constitutional question regarding whether Tinker should apply to off-campus speech. B.L., he said, could be resolved simply on the question of whether the speech was considered to be off-campus, since there was no argument that it was disruptive to the classroom.
"The case before us does not involve 'school-supervised channels,' nor does it concern speech that carried the school imprimatur, or was violent or threatening," Ambro said. "So it comes as no surprise that the majority does not give guidance on how its new rule is to be applied."
Sara Rose of the Pennsylvania chapter of the American Civil Liberties Union argued the case on behalf of B.L., while Michael Levin of Levin Legal Group in Huntingdon Valley, Pennsylvania, argued the case for the school.
In a press statement, the ACLU said the "landmark decision" marked the most expansive ruling on students' off-campus speech rights in the country.
"Our client was out of school, on her own time, and not involved in a school activity when she made the Snapchat post, and the school went well beyond its power in disciplining her for her speech," Rose said in the statement. "We are grateful that the court understood that the same free speech principles apply whether a student is kicked off the cheerleading team or suspended from school for expression that occurs off campus."
Levin did not immediately return a message seeking comment.
According to Krause, the student, referred to only as B.L., was kicked off her cheerleading squad after a coach found out that she and a friend posted a snap of themselves holding up their middle fingers with a caption that read, "fuck school fuck softball fuck cheer fuck everything." Her parents eventually sued the school, saying its decision violated B.L.'s First Amendment rights.
Regarding the question of whether the online speech was on- or off-campus, Krause looked to its 2011 decisions in Layshock v. Hermitage School District and J.S. v. Blue Mountain School District and determined that B.L.'s snaps, which were taken off school grounds and during the weekend, could not be considered on-campus speech.
"J.S. and Layshock yield the insight that a student's online speech is not rendered 'on-campus' simply because it involves the school, mentions teachers or administrators, is shared with or accessible to students, or reaches the school environment," Krause said. "And while the snap mentioned the school and reached MAHS students and officials, J.S. and Layshock hold that those few points of contact are not enough. B.L.'s snap, therefore, took place 'off-campus.'"
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